Question ID: 3461
Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Article: 184(2)
Status: Rejected
Date of submission: 14 Nov 2025
Question
Insurers are required to conduct adequate reporting on the funds to apply the look through approach. If the look through approach cannot be applied (whether because of the investment policy or inadequate reporting), then the investment may need to be treated as type 2 equity with 49% + SA. When this happens, would this fund be still considered to have separately Concentration Risk contributed to the whole investment portfolio?
EIOPA answer
This question has been rejected because the issue it deals with is already explained or addressed in Article 184 of the Delegated Regulation (EU) 2015/35. Article 184(2) provides a closed list of assets to be excluded from the calculation base of the market risk concentration sub-module. Should the fund not fall under any of the exclusions of Article 184(2), it would be part of the calculation base of the market risk concentration sub-module.